G.R. No. 225961 , January 06, 2020
The People of the Philippines, Plaintiff-Appellee, v. Paolo Luis Gratela y Davillo, Accused-Appellant.

FACTS

Accused-appellant Paolo Luis Gratela y Davillo was charged with the statutory rape of AAA, a seven-year-old girl, alleged to have occurred in July 2007 in Makati City. During arraignment, he pleaded not guilty. The parties stipulated that the court had jurisdiction and that the victim was seven years old at the time of the alleged crime. The prosecution presented the victim (AAA), her mother (BBB), the investigating police officer (PO2 Mary Grace Agustin), and the medico-legal officer (Police Chief Inspector Marianne S. Ebdane, M.D.). AAA testified that in July 2007, she went to the accused’s house, where he pulled down her shorts and underwear and his own clothes, then rubbed his penis against her vagina, causing her pain. She did not report the incident until April 15, 2009, after being triggered by a television show depicting rape. The medico-legal examination conducted on April 16, 2009, revealed a healed laceration on AAA’s hymen, which the medico-legal officer concluded was evidence of blunt force or penetrating trauma. The accused denied the allegations, claiming he was often not at home and suggesting the complaint was motivated by money, as his father worked abroad. The Regional Trial Court (RTC) found him guilty of statutory rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for statutory rape.

RULING

The Supreme Court denied the appeal and affirmed the CA decision with modification. The Court held that all elements of statutory rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353 , were proven beyond reasonable doubt: (1) the accused is a man; (2) he had carnal knowledge of a woman; and (3) the offended party was under twelve years of age. The victim’s positive identification of the accused, her credible testimony detailing the sexual act and the pain she felt, and the corroborating medico-legal report showing a healed hymenal laceration consistent with penetrating trauma established carnal knowledge. The defense of denial and alibi could not prevail over the victim’s positive testimony. The Court also found the delay in reporting the crime sufficiently explained by the victim’s young age and fear. The penalty of reclusion perpetua was affirmed. The awards of civil indemnity, moral damages, and exemplary damages were each set at P75,000.00, all subject to 6% interest per annum from the finality of the decision until fully paid.